RCRABrownfields
RCRA  Brownfields
or Not?
Partnering with States and Local Communities
               Determining if a site is a potential RCRA Rrownf ields
               Prevention project
                Factors Potentially Indicating a
                  RCRA Brownfield With
                 Redevelopment Potential
                     Factors Generally Indicating
                      Not a RCRA Brownfield
The property is, or will be, subject to
RCRA cleanup requirements.
The property, or a part of the property,
is abandoned, idle, or not fully utilized.
The property, or a part of the property,
will potentially be put out of use in the
near future.
A new company/owner/operator is
expected to take over and the new
use is not fully determined.
The local community is not satisfied with
the current status of the property.
Concerns about real or perceived
hazardous waste contamination at the
property are causing a delay in cleanup
and reuse.
The property is in a location where there
is interest in using the land (the site is
located in a blighted community or other
community that could benefit by bringing
the land back into use).
The property is located in a Brownfields
Community or is part of an area-wide
Brownfields Assessment.
The property is not regulated by RCRA.
The property is operating efficiently,
and/or providing a community benefit.
The current owner/operator is
financially sound and will continue to
use the property.
The property has long-term operating
prospects under its current use.
The local community is satisfied with
the current status of the property.
There are no environmental concerns
affecting redevelopment or use of the
property.
There is no market for the property
regardless of its condition.
The property is not located in an area
where reuse of the land is desirable.

-------
RCRABrownfields
                               The current owner is actively looking
                               to redevelop the property.
                               The local community is interested in
                               revitalizing or reusing the land or
                               there is a developer interested in the
                               site or a parcel of the property.
The current owner has no interest in
redeveloping or transferring ownership
of the property.
The local government is unwilling
to acquire the property through
eminent domain from a reluctant
owner.
                               Questions to ask once you have determined that your site
                               maybe a potential RCRABrownfield

                               1. What cleanup programs apply or are options at the property (CERCLA, RCRA, VCP,
                                 state non-RCRA programs)?
                                 a.  If more than one program, are the implementing agencies coordinating?

                               2. What are current issues are delaying cleanup and reuse of this land?

                               3. How much is known about the contamination?
                                 a.  Fully understood
                                 b.  Perceived but not defined
                                 c.  More information needed

                               4. Is the community involved in the plan to clean up the land and get the land back
                                 into reuse?
                                 a.  Have community organizations expressed interest in how the land is used?
                                 b.  Has there been or will there be outreach to the community?

                               5. Are there entities that have expressed interest in reusing the land?
                                 a.  Are they aware  of the variety of funding mechanisms that brownfields may be
                                    able to use towards cleanup and development?
                                 b.  Have they checked federal, state and local sources for available funding?

                               6. If no entity is interested in reusing the land, what steps need to be taken to match up
                                 an entity with the land? (Is more assessment or cleanup needed to foster a deal?)

                               7. Is future use confirmed to the  extent that it can be incorporated into cleanup plans?

                               8. What are the scheduling needs of the developer, and how can these needs be
                                 accommodated while still meeting any RCRA cleanup goals for the property?

                               9. Are there any RCRA reforms or innovative approaches that can be used at this
                                 property to speed up the process (voluntary RCRA order, state voluntary cleanup
                                 program, etc.)?

                               You can read more about EPA's RCRA program at: http://www.epa.gov/correctiveaction.

                               You can read more about EPA's RCRA Brownfields Prevention Initiative at:
                               http ://www.epa.gov/swerosps/rcrabf/index.html.

                               The EPA Brownfields  web site for more general brownfields information is:
                               http://www.epa.gov/brownfields.
                                                            Solid Waste and
                                                            Emergency Response
                                                            (5102G)
                 EPA 530-F-02-003
                 October 2002
                 www.epa.gov/osw/cleanup.htm

-------